The UK Financial Conduct Authority (FCA) issued CP25/18—a sweeping proposal to bring nearly 38,000 firms under expanded non-financial misconduct (NFM) rules. For the first time, solo-regulated firms will be held to the same behavioral standards as banks. 

The message is clear: Culture is no longer just an HR concern. It’s a regulatory control. 

This white paper breaks down what CP25/18 means for Compliance, HR, Legal, Front Office, and senior management teams—including how to build the systems and oversight needed to meet the FCA’s new expectations. 

What you’ll learn: 

• The scope of the new COCON and FIT guidance—and who’s now in scope 

• Why personal conduct outside of work could now be a regulatory breach 

• What “Should you have known?” means for senior managers and SMFs 

• How HR structure affects whether non-regulated employees fall under FCA rules 

• What surveillance, documentation, and audit trails firms need in place 
• How Shield Surveillance helps firms monitor culture as rigorously as they monitor trading 

Learn how to stay ahead of regulatory scrutiny and meet the FCA’s “Should you have known?” standard.